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The PCI SAQ Problem: Versions Are Much Too Incomplete

Written by Walter Conway
September 20th, 2011

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

The shortened versions of the Self-Assessment Questionnaire (SAQ) have only one problem: They are incomplete. There are PCI requirements every merchant should meet beyond what is specified in any shortened SAQ. Any retailer that limits its PCI compliance effort to completing one of the shortened SAQs trades off security for compliance. That is, any merchants who think they need only meet the requirements of a shortened SAQ risk a data compromise that can result in ruinous fines and land them in the headlines for reasons they would rather not be there.

The SAQ is an excellent starting point. But it is not (and does not promise to be) an all-inclusive approach to achieving—not just validating—PCI compliance. In a previous column, I noted the PCI Council’s point that slavishly (my terminology) completing a SAQ may not be enough to be PCI compliant. As the Council states in the SAQ Instructions and Guidelines: “According to payment brand rules, all merchants and service providers are required to comply with the PCI DSS in its entirety.”

What is a merchant to do? On the one hand, they may qualify to use a shortened SAQ with as few as 12 items. On the other hand, the same PCI Council that developed the SAQ still expects merchants to comply with each of the 280-plus requirements of PCI. Assuming these conflicting thoughts haven’t caused a merchant’s head to explode, I would like to offer a solution.

That solution is to use the SAQ as a guideline. It is a starting point. Merchants need to go beyond their SAQ’s requirements. They need to take advantage of their knowledge of their operations and network to include other PCI requirements they should meet to secure their systems and protect their business.

(Related story: New PCI P2PE Rules Drop Compliance Requirements To 2)

Merchants who qualify for SAQ A could outsource their card processing to a PCI-compliant service provider. SAQ A applies only to card-not-present situations and, as with all the shortened SAQs, the merchant stores no electronic cardholder data. The typical SAQ A merchant hosts a Web site that at some point redirects the customer to the processor’s hosted order page where all cardholder data is processed. SAQ A merchants, therefore, rely entirely on their PCI-compliant processor for all card processing.

SAQ A includes 12 questions that cover parts of only two PCI requirements: parts of Requirement 9, for securing any paper records, and Requirement 12.8, for managing the service provider. That’s it. Because the merchant has a Web site, I would suggest it is a glaring vulnerability that is not addressed currently by the SAQ. It is not only I who thinks this way. Visa Europe issued a bulletin in April 2010 warning about attacks on SAQ A-type merchants.


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